ML15292A013

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ERO Staffing and Training Teleconference with NRC Staff
ML15292A013
Person / Time
Site: Pilgrim
Issue date: 10/20/2015
From:
Entergy Nuclear Generation Co
To:
Office of Nuclear Reactor Regulation
Venkataraman B
References
Download: ML15292A013 (11)


Text

Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400

Agenda

  • Introduction of Participants
  • Background and History
  • Problem Statement
  • Proposed Resolution
  • Basis for Change
  • Intended Actions
  • NRC Staff Questions and Perspective
  • Conclusions 2

Introduction of Participants

  • NRC Staff
  • Entergy - Pilgrim 3

Background and History

  • July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
  • Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
  • 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
  • Immediate actions; RP Tech added back to shifts; 4

Problem Statement

  • Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.

5

July 14, 2006 Letter: Chem Tech Training 6

Proposed Resolution

  • Entergy proposal:

o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation

  • Entergy has concluded this change is acceptable 7

Basis for Change

  • Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
  • Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
  • OE review identified similar implementations
  • February 5, 2007 NRC Staff letter concluded:

o Previous Entergy proposal met requirements of:

10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8

Intended Actions

  • Conference call with NRC Staff
  • Preparation and submittal of request for prior NRC Staff review and approval
  • Revise training
  • Revise ERO staffing 9

NRC Staff Questions and Perspective 10

Conclusions

  • Proposed change in Chemistry Technician is appropriate based on ERO assignments
  • Proposed change is justified by staffing study
  • Entergy intends on submitting the proposed change for prior NRC review and approval 11

Pilgrim Nuclear Power Station ERO Staffing and Training Teleconference with NRC Staff October 20, 2015 10/15/15 1400

Agenda

  • Introduction of Participants
  • Background and History
  • Problem Statement
  • Proposed Resolution
  • Basis for Change
  • Intended Actions
  • NRC Staff Questions and Perspective
  • Conclusions 2

Introduction of Participants

  • NRC Staff
  • Entergy - Pilgrim 3

Background and History

  • July 14, 2006 letter from Entergy to NRC Staff o ERO substitution: Chem Tech for RP Tech o Training for Chem Techs described
  • Feb 5, 2007 letter from NRC Staff to Entergy o Change does not decrease effectiveness of plan o No NRC approval necessary
  • 2015: Entergy determined Chem Tech training not consistent with July 14, 2006 letter
  • Immediate actions; RP Tech added back to shifts; 4

Problem Statement

  • Level of training for Chem Techs acting for RP Techs described in July 14, 2006 letter exceeds actual requirements of the ERO function.

5

July 14, 2006 Letter: Chem Tech Training 6

Proposed Resolution

  • Entergy proposal:

o Return to onshift Chem Techs fulfilling the RP Tech ERO function for first 30 minutes of ERO initiation o Reduce the scope of Chem Tech training o Submittal to NRC for review and approval prior to implementation

  • Entergy has concluded this change is acceptable 7

Basis for Change

  • Reduced level of training - consistent with limited specific actions of the Chem Techs within 30 minutes
  • Specific on-shift staffing study supports limited scope of responsibilities of Chem Tech for RP Techs
  • OE review identified similar implementations
  • February 5, 2007 NRC Staff letter concluded:

o Previous Entergy proposal met requirements of:

10CFR50.47(b)(2) - adequate staffing provided 10CFR50, App E, IV.A - organization for coping o Chem Tech training considered an enhancement o No decrease in effectiveness / no NRC approval required 8

Intended Actions

  • Conference call with NRC Staff
  • Preparation and submittal of request for prior NRC Staff review and approval
  • Revise training
  • Revise ERO staffing 9

NRC Staff Questions and Perspective 10

Conclusions

  • Proposed change in Chemistry Technician is appropriate based on ERO assignments
  • Proposed change is justified by staffing study
  • Entergy intends on submitting the proposed change for prior NRC review and approval 11